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SDMS DocID 2049154 SECOND FIVE-YEAR REVIEW REPORT For RESIN DISPOSAL SITE JEFFERSON BOROUGH ALLEGHENY COUNTY, PENNSYLVANIA August 2005 PREPARED BY: United States Environmental Protection Agency Region III Philadelphia, Pennsylvania Approved by: , Date: Abraham Ferdas, Director Hazardous Site Cleanup Division U.S. EPA, Region III

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SDMS DocID 2049154

SECOND FIVE-YEAR REVIEW REPORT

For

RESIN DISPOSAL SITEJEFFERSON BOROUGH

ALLEGHENY COUNTY, PENNSYLVANIA

August 2005

PREPARED BY:

United States Environmental Protection AgencyRegion III

Philadelphia, Pennsylvania

Approved by: , Date:

Abraham Ferdas, DirectorHazardous Site Cleanup DivisionU.S. EPA, Region III

Table of Contents List of Acronyms 3 Executive Summary 4 Five-Year Review Summary Form 5 I. Introduction 6 II. Site Chronology 7 III. Background 8 IV. Remedial Actions 11 V. Progress Since Last Five-Year Review 14 VI. Five-Year Review Process 18 VII. Technical Assessment 21 VIII. Issues 22 IX. Recommendations and Follow-up Actions 22 X. Protectiveness Statement 23 XI. Next Review 23 Tables

Product Recovery Activities Table 1 Data Summary Table Table 3

Attachments

Figure 3 Response Actions Plan Sampling Locations and Site Map Attachment 1 Resin Disposal Site Photographs Attachment 2

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List of Acronyms ARARs Applicable or Relevant and Appropriate Requirements AOC Administrative Order on Consent BTEX Benzene, Toluene, Ethylbenzene, and Xylene CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency FS Feasibility Study HI Hazard Index IC Institutional Control MCLs Maximum Contaminant Levels mg/kg milligrams per kilogram (mg/kg) NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operations and Maintenance OU Operable Unit PADER Pennsylvania Department of Environmental Resources PADEP Pennsylvania Department of Environmental Protection PICCO Pennsylvania Industrial Chemical Corporation PRP Potentially Responsible Party RA Remedial Action RAO Remedial Action Objective RCRA Resource Conservation Recovery Act RD Remedial Design RDS (PICCO) Resin Disposal Site RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RP Responsible Party RPM Remedial Project Manager SARA Superfund Amendments and Reauthorization Act of 1986 SDWA Safe Drinking Water Act VOC Volatile Organic Compound WEG Weavertown Environmental Group WESA West Elizabeth (PA) Sanitary Authority

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Executive Summary

The remedies for the Resin Disposal Superfund Site in Jefferson Township, Allegheny County, Pennsylvania included: remediation of the landfill (i.e.; in-place containment via installation of multi-layered capping system); collection and management of leachate; installation of an oil/water separator; offsite disposal of wastewater collected in the oil/water separator and of collected free product; fencing the property; institutional controls; monitoring of groundwater; monitoring and collection of recoverable free product; and; standard operations and maintenance. The trigger for this five-year review is the signature date of the previous Five-Year Review report, September 19, 2000. The purpose of a Five-Year Review is to ensure that the cleanup remains protective of public health and welfare and the environment and is functioning as designed.

The assessment of this Five-Year Review found that the Operable Unit (OU)-l and OU-2 remedies were constructed in accordance with the requirements of the 1991 Record of Decision (ROD) and the 1995 ROD and that the remedies are functioning as designed.

The remedies for OU-1 and OU-2 are fully protective of human health and the environment. In accordance with the June 28, 1991 ROD, use restrictions have been placed on the property to alert prospective buyers to the presence of hazardous substances on site and to prohibit future development. The implementation of use restrictions on the Resin Disposal Site provides an added measure of institutional control to prevent exposure to contaminated groundwater.

Currently groundwater monitoring and operations and maintenance activities are being conducted at the site to ensure the remedies continue to be protective.

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Five-Year Review Summary Form

SITE IDENTIFICATION Site name (from WasteLAN): Resin Disposal Site USEPA ID (from WasteLAN): PAD063766828 Region: III State: PA City/County: Jefferson Borough/Allegheny County

SITE STATUS NPL status: Deleted Remediation status: Complete Multiple OUs*? Yes Construction completion date: 11/20/1996 Has site been put into reuse? No

REVIEW STATUS Lead agency: EPA Author's name: Rashmi Mathur Author's title: Remedial Project Manager Author's affiliation: EPA EPA’s Review period:** 09/02/2004 to 09/19/2005 Date(s) of site inspection: 06/22/2005 Type of review: Post-SARA Review number: Second Triggering action: Previous Five-Year Review Report Triggering action date (from WasteLAN): 09/12/2000 Due date (five years after triggering action date): 09/12/2005 * ["OU" refers to operable unit.] ** [Review period should correspond to the actual start and end dates of the five-year review in WasteLAN.] Issues: No issues were identified during the technical assessment and other five-year review activities. Recommendations: There are no recommendations and follow-up actions (other than continue with standard operations and maintenance) since no issues were identified in Section VIII. Protectiveness Statement(s): The remedy is protective of human health and the environment. All threats at the Site have been addressed through upgrading the multilayer cap of the contaminated soils and through the oil/water separator, collecting and separating wastewater and oil from the leachate collection system. (The wastewater is sent to the wastewater treatment facility and oil is collected and disposed off-site, thus preventing exposure to or ingestion of contaminated groundwater.) The fence around the landfill restricts access. The implementation of institutional controls, which alert prospective buyers of contaminants on-Site and place prohibitions on future development, addresses future threat. Other Comments:

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Five-Year Review Report For

Resin Disposal Jefferson Borough, Pennsylvania

I. Introduction

The purpose of the Five-Year Review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this Five-Year Review report pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 Code of Federal Regulations

§300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

The EPA Region III has conducted a Five-Year Review of the remedial actions implemented

at the Resin Disposal site in Jefferson Borough, Allegheny County, Pennsylvania. This review was conducted from September 2004 to August 2005. This report documents the results of the review. Mr. Joseph Keller, Hercules Incorporated (Hercules), and Weavertown Environmental Group (WEG) representatives (Timothy Ratvasky, Kelly Hamilton, and Craig Wyda) assisted in providing data. WEG has been contracted by Hercules to provide site management, operations maintenance, and sampling for the Resin Disposal site.

This is the second Five-Year Review for the Resin Disposal site. The triggering action for this review is the signature date of the previous Five-Year Review report, as shown in EPA's WasteLAN database: September 19, 2000. The Five-Year Review is required due to the fact that contaminants remain at the site. The purpose of a Five-Year Review is to ensure that a remedial action remains protective of public health and welfare and the environment and is functioning as designed.

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II. Site Chronology

Date Event 1950 to 1964 Pennsylvania Industrial Chemical Corporation (PICCO) utilized the site as an

industrial landfill for depositing waste materials from PICCO's resins manufacturing plant

1973 Hercules Incorporated purchased the business and facilities, including the landfill property from PICCO

April 1, 1979 Initial discovery of problem or contamination 1980 to 1984 Field investigations were conducted for Hercules by Roy F. Weston, Inc. and

Murray Associates to provide information on groundwater conditions in the coal formation, deep bedrock, and on the extent of contaminated soils downslope of the landfill

April 1982 Superfund Site Investigation completed December 1982 Site received a Hazard Ranking System score of 37.69 and was proposed for

the National Priorities List (NPL) 1983 Leachate collection trench installed below the lower landfill dike to collect

leachate and ground water September 1983 The landfill was placed on the NPL November 2, 1987 Hercules enters into a Consent Order and Agreement with the Pennsylvania

Department of Environmental Resources (PADER) to conduct a Remedial Investigation/Feasibility Study (RI/FS)

February 1988 RI work plan approved by PADER and EPA March 1991 Final RI submitted to PADER and EPA May 1991 Final FS submitted to PADEP and EPA June 28, 1991 Record of Decision (ROD) selecting Remedy is signed February 1992 Consent Decree issued by EPA for Remedial Design and Remedial Action

(RD/RA) for OU-1 (landfill) December 1992 Final RD Work Plan was approved by EPA December 1994 Final Oil/Water Separator Design was approved by EPA September 29, 1995 No Further Action ROD for OU-2 (groundwater) including long-term

monitoring of the groundwater was issued and Final Design for landfill cap and fence was approved by EPA

September 1996 Administrative Order by Consent (AOC) for OU-2 between Hercules Incorporated and EPA

Fall 1996 Landfill Closure complete November 20, 1996 Construction Completion Date November 20, 1996 Final Close-out Report 1999 Through RI and groundwater monitoring, it was determined the residential

water users were not affected by Site related contaminants and sampling of residential wells was discontinued

September 19, 2000 First Type 1 Five-Year Review was completed by EPA October 21, 2003 Deletion from NPL

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III. Background Physical Characteristics

The following information was obtained from the first Five-Year Review of the Resin Disposal Site (the Site) prepared by the U.S. Environmental Protection Agency.

The Site is located about one half mile west of the town of West Elizabeth in Jefferson Borough, Allegheny County, Pennsylvania and comprises approximately 26 acres (Figure 1). West Elizabeth is a mixed commercial, industrial, and residential area with a population of 565 (2000 census). According to U.S. Census Bureau 1990 records, the population within a one-mile radius of the site is 1,819. The Site was operated as a landfill between 1950 and 1964. The landfill is located in the head of a narrow valley on the site of a former coal mine in which the landfill comprises approximately 2 of the 26 acres.

The Site is surrounded by a suburban residential area to the north and west and by undeveloped property to the south and east. A trailer park and several residential homes are located approximately 1/4 mile southeast and down slope of the Site. The topography of the area is characterized as relatively level highland, with deeply eroded stream valleys. Coal was strip mined from the valley prior to 1950 in the area surrounding the Site.

An unnamed stream originates in the northeastern portion of the Site and runs through the Site down slope to the southeast, ultimately discharging into the Monongahela River approximately one-half mile from the Site boundary. Land and Resource Use

The Site is surrounded by a suburban residential area to the north and west and by undeveloped property to the south and east. A trailer park and several residential homes are located approximately 1/4 mile southeast and downslope of the Site.

Major sources of groundwater in the area are alluvial valley fill aquifers in the large river valleys. Groundwater within the Site area however, is limited to storage in fractured bedrock, the voids left from coal mining and as perched groundwater in the unconsolidated soils down slope of the landfill. Groundwater quantities are low in the bedrock due to the generally unfractured condition of the deep bedrock. The coal seam contains groundwater that is not considered potable due to its low pH and high concentrations of metals. The flow of groundwater in the unconsolidated soils downslope generally parallels the surface topography. Although quantities of groundwater are available for domestic use, most of the residents in the vicinity of the Site are connected to the public water supply. A review of existing data and discussions with local residents identified six residential wells in the vicinity of the Site. History of Contamination

Between 1950 and 1964, prior to the Resource Conservation and Recovery Act, as amended (RCRA), 42 U.S.C. 6901 et seq., the Pennsylvania Industrial Chemical Corporation (PICCO) Plant generated and deposited an estimated 85,000 tons of production wastes into the onsite landfill. As a

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result of these activities, the Site is known as the Resin Disposal Site. The wastes consisted mainly of clay poly cakes and dechlor cakes, which are composed of petroleum and coal derived chemicals mixed with clay. The waste materials were dumped into the landfill as a slurry which collected behind a dike constructed across the upper end of the strip-mined valley. Precipitation runoff from the surrounding hillsides along with any free water from the waste materials collected within the active landfill behind the dike. After the land filling activities ceased, PICCO placed a poorly graded, native clayey soil cover, ranging in thickness from four to ten feet, over the surface of the landfill. As a result, the direct precipitation and run on from the surrounding hills ponded at times on the landfill cover. Some of the water infiltrated the cover, recharging the waste material and adjacent groundwater system. The remainder of the water evaporated or ran off to the unnamed stream. The waste was contained within the landfill behind earthen dikes (Figure 2). Over time, residual product oils decanted from the waste materials as free product. The free product and infiltrated water migrated southeast through the landfill dike into downslope soils and also southwest into mine voids, in the adjacent Pittsburgh Coal Formation.

Prior to 1950, the original coal was strip-mined and deep mined throughout the valley. The deep mining was done through a process known as room and pillar mining, which resulted in mine voids throughout the Site. At the location of the landfill, approximately 20 feet of waste was deposited in place of the mined coal. No records exist of the actual wastes deposited in the landfill. Initial Response

Hercules purchased the business and facilities, which includes the landfill property, from PICCO in 1973. Between 1980 and 1984, a series of field investigations were conducted to provide information on groundwater conditions in coal formation, deep bedrock, and on the extent of contaminated soils downslope of the landfill. Roy F. Weston, Inc., and Murray Associates conducted the field investigations for Hercules. The data from these investigations indicated that contaminants had migrated beyond the buried waste in the landfill and could be found in groundwater in the Pittsburgh Coal Formation and in downslope soils and perched groundwater. As a result of these investigations, Weston recommended that Hercules install a leachate collection trench below the lower landfill dike to collect leachate and groundwater. This trench was installed in 1983 and is still operating. Liquids collected in the trench are directed to an oil/water separator. The oil was formerly burned at the Hercules Jefferson Plant boiler until June 2002. The oil is currently transported to AES in Morgantown, West Virginia for fuel blending. The water is discharged from the separator to the Jefferson Borough Sanitary Sewer System and then to the West Elizabeth sewage treatment plant.

A Superfund Site Investigation was completed in April 1982. The Site was proposed for the National Priorities List (NPL) in December 1982 and was placed on the NPL in September 1983. On November 2, 1987, Hercules entered into a Consent Order and Agreement with the Pennsylvania Department of Environmental Resources (PADER) to conduct a Remedial Investigation/Feasibility Study (RI/FS) at the Site. The RI work plan was approved by the PADER and the EPA in February 1988, and work began on March 17, 1988. The purpose of the RI/FS was to characterize the site for potential remediation. This included an extensive study of the extent of contamination of the soils, groundwater, and surface water associated with the landfill. A final RI was submitted to the PADER and the EPA in March 1991, and the final FS was submitted in May 1991.

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The EPA has categorized the Site into two operable units. Operable Unit One (OU-1) addresses remediation of the landfill, the adjacent contaminated soils, non-aqueous floating product present in the subsurface mine voids of the Pittsburgh Coal Formation, and monitoring of onsite groundwater. Operable Unit Two (OU-2) addresses offsite groundwater, seeps, and residential wells. Basis for Taking Action

The RI identified and evaluated Site-related contaminants, the potential migration routes, and exposure pathways for human and ecological receptors. The following discussion of contamination is based on the RI and is reflective of conditions at the time the RI was written. Free Product

Over time, residual product oils were decanted from the waste materials as free product. The free product and infiltrated water migrated through the landfill dike into downslope soils and also southwest into mine voids in the adjacent Pittsburgh Coal Formation. Mine Voids

The mine workings within the Pittsburgh Coal Formation provide a honeycomb of voids below the land and act as conduits for groundwater flow. Data collected during the RI has verified that some voids are open while other voids are partially or mostly collapsed. Mine voids and collapsed rubble are expected to be the preferential pathways for groundwater flow, whereas pillars and walls (i.e., unmined sections of the Pittsburgh Coal Formation) within the mine are expected to impede groundwater flow. Groundwater System and Contamination

The groundwater system within the Pittsburgh Coal is well constrained since the downgradient extent of the system is defined by the outcrop of limit of the coal, which was strip mined. Seeps and springs are common along the outcrop and represent groundwater discharge from the mines. Based on the significant permeability contrasts between the mine voids and the coal, it is anticipated that most of the groundwater flow is through the mine voids. Groundwater in the mine voids downgradient of the landfill contains aromatic organic compounds (i.e., benzene, toluene, ethylbenzene, xylene [collectively BTEX], naphthalene, and 2-methylnaphthalene) as contaminants dissolved from the waste materials in the landfill and from free product in the adjacent mine voids.

No landfill-related contaminants were detected at the seeps downgradient from the landfill during the OU-2 RI and no Site-related compounds were found in any of the residential wells sampled downgradient from the landfill. Through the RI and following groundwater monitoring, it was determined that the residential water users were not affected by Site-related contaminants, so sampling of residential wells was discontinued in 1999.

A groundwater system was found below the Pittsburgh Coal Formation, but at the three monitoring wells (TW-5, TW-6, and TW-25) where the groundwater was sampled, the formation was very tight and the yield was very low. Monitoring wells TW-5 and TW-6 were abandoned during the RI activities. Site-related contaminants were not found in the groundwater zones of the deeper groundwater system and subsequent investigation of this unit was deemed unnecessary.

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IV. Remedial Actions Remedy Selection

The EPA has categorized the Site into the following two operable units. Operable Unit 1

OU-1 addresses remediation of the landfill, the adjacent contaminated soils, non-aqueous floating product present in the subsurface mine voids of the Pittsburgh Coal Formation, and monitoring of onsite groundwater. A June 28, 1991 ROD documented the selected remedial action for OU-1, which included: installation of a multi-layer cap; reinforcement and upgrading of the lower landfill dike to increase its stability; installation of an upgraded oil/water separator downslope of the leachate collection system, with discharge of aqueous phases to a publicly owned treatment works; relocation of a sanitary sewer; institutional controls which include use restrictions to alert prospective buyers to the presence of hazardous substances on site and to prohibit future development; construction of a fence around the perimeter of the Site property to prevent unauthorized access; offsite reclamation of non-aqueous phase liquids (NAPLS) via recovery wells for use as an energy source; and implementation of a Site maintenance and long-term groundwater monitoring program. Operable Unit 2

OU-2 addresses offsite groundwater, seeps, and residential wells. A No Further Action ROD for OU-2, which included long-term monitoring of the groundwater, was issued on September 29, 1995. Remedy Implementation Operable Unit 1

On October 9, 1991, Hercules submitted a good faith offer to perform the Remedial Design and Remedial Action (RD/RA) for OU-1. After a period of negotiations with the EPA, Hercules signed a Consent Decree on February 11, 1992 to perform the RD/RA at the Site. On May 11, 1992, Roy F. Weston, Inc. was approved by the EPA as the RD contractor for Hercules. On December 4, 1992, the final RD Work Plan, written by Weston for Hercules, was approved by the EPA. A Final Oil/Water Separator Design was submitted prior to the landfill cap design. It was approved on December 21, 1994. The Final Design for the landfill cap and the fence was approved by the EPA on September 29, 1995.

The remedial objectives for OU-1 specified the remediation of the landfill. A multi-layer cover equivalent to a RCRA Subtitle C landfill cap was placed over the existing landfill. Infiltration controls were also installed around the perimeter of the landfill to control run-on and runoff. Construction of the cap began in June of 1995 and was completed in the fall of 1996. The completed landfill cover system included a low permeability clay liner, geomembrane, drainage layer and surface drainage channels. The cap surface is covered in grass. The lower landfill dike was reinforced with approximately 5,000 tons of clean soil, regraded, and hydroseeded. In total, 57,000 tons of clean fill, 3,200 tons of topsoil and 3,800 tons of rip-rap were used to cover and stabilize the Site. A security

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fence was also installed around the perimeter of the Site and the landfill.

Surface water sampling conducted during the period 1991 through 1998 showed that the multi-layer cover and product recovery program resulted in a decrease of Site-related constituents in the unnamed stream to levels at or below Maximum Contaminant Levels. Surface water sampling was subsequently discontinued in 1998.

In addition, the remedial objectives for OU-1 specified the monitoring of onsite groundwater and recovery of free-phase floating product in the mine voids of the Pittsburgh Coal Formation. Free phase floating product is collected from on-site recovery wells and by the oil/water separator.

The Weavertown Group measures free product thickness and groundwater levels on a quarterly basis in on-site wells PH-1, PH-2, PH-10, PH-11, TW-2, TW-7, TW-13, TW-14, TW-21, TW-22 and TW-24. Recoverable quantities of free product have been historically bailed from recovery wells PH-10, TW-2 and TW-14, and discharged into the Site oil/water separator. Since July of 1999, virtually no recoverable free product has been measured in Site recovery wells (Table 2). Free product recovery was reduced from a monthly to the current quarterly frequency during 1999, due to the minimal thickness of free product measured in Site wells.

Accumulated free product is removed from the oil/water separator on a quarterly basis. Product accumulation in the reservoir of the oil/water separator is monitored by a float system connected to an autodialer. Free product removal is performed upon notification from the autodialer. Approximately 300 gallons of free product are removed from the oil/water separator during each event. On May 20, 2004, the oil/water separator was emptied, pressure washed and visually inspected in accordance with the oil/water separator maintenance program. The separator was found to be free of leaks, cracks and other damage.

Quarterly groundwater sampling and laboratory analyses performed in OU-1 initially included on-site monitoring wells TW-7, TW-13, TW-14, TW-21, TW-22 and TW-23. Site-related indicator compounds included in the monitoring program include benzene, toluene, ethylbenzene, xylenes and naphthalene. Since the first quarter of 1998 through 1999, Site-related constituents were reported at detection levels or as non-detects in wells TW-7, TW-21, TW-22 and TW-24 (Table 3). Consequently, these wells were removed from the on-site groundwater monitoring program.

Groundwater samples have been collected from well TW-13 on a quarterly basis during the second 5-year report period. Analytical results for TW-13 are summarized in Table 3 and shown on Figure 3. Low to nondetectable concentrations of naphthalene and ethylbenzene and xylenes have been reported in the groundwater samples collected from TW-13 (Table 3). Groundwater samples have not been collected from TW-14, due to a measurable but unrecoverable thickness of free product on groundwater, and because there is insufficient water to collect a groundwater sample (Table 3). Operable Unit 2

Monitoring initially required under OU-2 included the quarterly sampling of off-site monitoring wells TW-17, TW-18, TW-19, TW-20, and TW-24, the quarterly sampling of three seeps (designated Seep 3, Seep 4, and Seep 5), and the sampling of residential wells during 1999. The seeps receive groundwater from the mine voids downgradient of the Site. The OU-2 monitoring wells listed above also monitor groundwater in the mine voids of the Pittsburgh Coal Formation, downgradient of the Site.

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No Site-related constituents were detected in samples collected from the seeps or the residential wells during the first 5-year review period (Table 3). Consequently, the seeps and residential wells were dropped from the OU-2 groundwater monitoring program during the second 5-year review period. Between the fourth quarter of 1998 through the fourth quarter of 1999, concentrations of Site-related constituents were reported as at or below analytical detection levels in the off-site monitoring wells. The sampling of off-site monitoring wells was discontinued during the second 5-year review period. However, groundwater levels are measured in off-site monitoring wells on a quarterly basis, during the sampling of on-site monitoring well TW-13. Free product has not been observed in any of the off-site monitoring wells.

System Operation/Operation and Maintenance

The landfill cover, landfill cap, and surface drainage channels are inspected at a minimum of every quarter. The landfill cap and landfill dike are periodically mowed to maintain the grass cover. In 1999, Hercules performed modifications to the drainage channels following a severe precipitation event. This work included the lining of drainage channels passing along the landfill dike with Reno mats and gabion baskets in order to contain and control surface water during precipitation events. In addition, the landfill access road was regraded. The landfill cover and drainage channels remain in operational condition.

The Site management activities were initially conducted by Hercules and Roy F. Weston, Inc. and are now conducted by Weavertown Environmental Group (WEG). WEG provides the following services to Hercules: Oil/Water Separator Product Removal and Disposal

Product in the discharge from the landfill underdrain system is separated from the flow and is accumulated in the product reservoir of the facility's oil/water separator. Based on historical Site work, the product reservoir in the oil/water separator requires evacuation approximately four times per year. Typically, eight 55 gallon drums of product are generated during each evacuation event.

Upon notification by the Site automated monitoring system, WEG evacuates the oil/water separator reservoir using a pump provided by Hercules into new DOT 17H drums, and transports the eight drums of product to the disposal facility (American Environmental Services, Inc., in Morgantown, West Virginia), in accordance with Department of Transportation regulations, under manifest as a hazardous waste liquid. Site Maintenance and Optimization of Operation and Maintenance

The following system operation/O&M is required until the next Five-Year Review:

• Hercules will sample wells TW-7, TW-17, TW-18, TW-20, TW-22, and TW-23 for BTEX and naphthalene, following a two-week notification to the EPA and Pennsylvania Department of Environmental Protection. EPA and PADEP will evaluate data to determine if these monitoring wells will be abandoned.

• Sampling of well TW-13 will be reduced to semiannually for BTEX and Napthalene until the next Five-Year Review. Sample TW-19, TW-21, and TW-24 semiannually for BTEX and Napthalene at each Five-Year Review Year.

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• On-site monitoring wells will continue to be gauged for LNAPL and depth to water on a semiannual basis until the next Five-Year Review. In the event that a recoverable quantity of LNAPL is detected in an on-site well, the LNAPL will be recovered and the on-site wells will be gauged for LNAPL thickness during the following quarter.

• Periodic (quarterly) inspections of the landfill cover, oil/water separator compound, and security fence will be performed, and maintained as required.

• Hercules will continue to operate the oil/water separator until the next Five-Year Review and perform operation and maintenance on the oil/water separator annually and provide records and raw water before and after cleaning the oil/water separator.

Site maintenance activities include:

• Inspection of the general condition of vegetative cover on the Site landfill, general

condition of gabions and Reno mats installed along the drainage ways, evidence of unauthorized entry or vandalism, condition of access roads, and any other pertinent observations.

• Spraying of landfill ditches, roadways and treatment compound with a broad-spectrum

herbicide (Roundup or equivalent) to control weed growth. Also perform minor weed cutting in these areas to address minor, sporadic weed growth in spray areas.

• Perform rotational mowing of the landfill. Alternate halves of the landfill cap will be

mowed during two proposed events. The "face" and accessible perimeter of the landfill cap will also be mowed. Mowing will be performed with a tractor and brush-hog style mower.

• Plant food plots at the rear of the landfill. One planting will be coordinated with the

fall mowing. The second planting will occur in the early spring. The planting will consist of winter wheat, oats, or similar game crop.

• Check on and maintain operation of the system autodialer.

• Inspection and cleaning the oil water separator periodically

• Inspection of the condition of the groundwater monitoring wells and security fence.

• Semiannual monitoring of groundwater monitoring wells

V. Progress Since Last Five-Year Review

In the previous Five-Year Review for Resin Disposal dated 9/19/00, the remedy was not fully protective because the institutional controls required by the 1991 ROD were not in place. In August 2002, Hercules executed and recorded the institutional controls required by the ROD, including use restrictions to alert prospective buyers to the presence of hazardous substances on-site and to prohibit future development.

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Additional recommendations in the prior Five-Year Review included excluding the seeps and

following monitoring wells from the monitoring program because no Site related groundwater contaminants had been observed for two consecutive years: TW-7, TW-17, TW-18, TW-19, TW-20, TW-21, TW-22, TW-23 and TW-24. These monitoring wells and seeps have been excluded from the monitoring program. Quarterly monitoring for monitoring well TW-13 will be collected and submitted to EPA annually and EPA will determine if further monitoring is necessary.

Additional monitoring wells: TW-7, TW-17, TW-18, TW-20, TW-22, and TW-23 needed to be sampled and the data provided to EPA and PADEP to determine if the wells can be abandoned. EPA also recommended that Hercules sample TW-19, TW-21, and TW-24 at every Five-Year Review Year, but this was not completed as of yet. EPA recommends sampling the following monitoring wells: TW-7, TW-17, TW-18, TW-20, TW-22, TW-23, TW-19, TW-21, and TW-24 at the next sampling event and provide the annual data to EPA and PADEP for evaluation.

The last Five-Year Review also included periodic inspection of the landfill and fence. The multi-layer cover and fence installed at the Resin Disposal Site continues to operate as designed, as indicated by continued improvements in groundwater quality, the reduction of recoverable free product in on-site wells, and no trespassers coming on Site. The positive impacts to groundwater quality continue to be realized, as indicated by the decrease in Site-related constituents reported for well TW-13. All Site-related constituents have been reported as below maximum contaminant levels or below analytical detection in water collected from TW-13 since third quarter 2001. The periodic inspections of the landfill and fence will continue.

In the previous Five-Year Review the LNAPL recovery was to continue quarterly until the next Five-Year Review. No recoverable quantities of free product have been reported in on-site monitoring wells since January 2000, and the thickness of free product in on-site wells has stabilized to between a sheen and 0.01 foot (Table 2). The leachate collection trench continues to operate as designed, with accumulated free product being removed from the oil/water separator on a quarterly basis. In 2004 cleaning and inspection of the oil/water separator was conducted. The LNAPL recovery and depth to water will continue on a semiannual basis until the next Five-Year Review. The operation and maintenance on the oil/water separator will continue but the Responsible Party needs to provide records and raw water data annually before and after cleaning the oil/water separator. 1. WEST ELIZABETH SANITARY AUTHORITY (WESA) SEWER

SYSTEM ODOR ISSUE

WESA has been experiencing odor issues with its sewer system for some time. From time to time, the odor issue manifests itself as complaints from a residential property located at 1037 6th Street, West Elizabeth, Pennsylvania. Over speculation that the source of the odors may be the discharge of the aqueous phase of material from the oil/water separator into the WESA sewer system, a meeting and Site visit were conducted on February 19, 2004 at the landfill and WESA 4th Street pumping station. A letter documenting the meeting and Site visit was provided to the USEPA Water Division.

The areas visited by Pennsylvania Department of Environmental Protection, the Allegheny Health Department, Representatives of Hercules included:

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• Landfill and oil/water separator compound • Manhole along Stilley Street at Alexander Drive • 4th Street Pumping Station • Manholes along 6th Street near the subject residence • P-trap and vent at 1037 6th Street

Landfill

Weavertown explained the operation of the landfill underdrain, fluid collection system, and oil/water separator. The participants walked to the top of the landfill and inspected the oil/water separator compound. James Shack of the PADEP closely inspected the drainageway passing beside and downgradient of the compound for evidence of product or odor. None were detected.

The weir structure in the oil/water separator compound was inspected, and a slight odor was detected. Edwin Watkins of the ACHD collected a water sample at the weir consisting of two, HC1-preserved, 40-mL VOA vials and one clear, 1-liter glass bottle. The water was slightly tinted, but otherwise clear. He was not certain of the analyses to be performed on the samples, but volatile and semivolatile organic analyses were indicated.

Prior to leaving the landfill, Weavertown explained the work performed in 2002 (lining of the sewers passing through the landfill, inspection of landfill manholes for odors, and installing P-traps and vents in the sewer lines of three homes on 6th Street) to address former odor complaints. Emphasis was placed on the occurrence of vapors after sewer connections were made to the sewer passing along Route 837, and occurrence of vapors when the ventilation blower at the pumping station was operated, possibly forcing vapors into the sewers. This condition was reiterated by Brian Secrest of WESA, who indicated that a more powerful blower had been installed to displace the strong chemical fumes existing in the pumping station. Mr. Secrest also emphasized that the WESA staff felt that the odors detected at the pumping station were different from, and not associated with, the landfill. Stilley Street/Alexander Drive Manhole

The manhole was opened, and a minor odor consistent with the oil/water separator discharge was detected. Wastewater flow was clear, and the manhole was clean.

PADEP staff asked whether other complaints were submitted from residences along Stilley Street or from 6th Street. Weavertown and WESA indicated that they were aware of only one complaint, from 1037 6th Street. 4th Street Pumping Station

Upon opening the door to the pumping station, a nearly overpowering solvent-type odor was immediately detectable. All participants agreed that the odor was much stronger than experienced in the oil/water separator compound or downstream manhole, and did not match the odor in the oil/water separator outflow at the landfill. Brian Secrest indicated that the odors in the building were frequently much stronger, and that he had installed an oversized blower to force air into the building and its two sub-basements to permit human access. WESA also indicated that they used an Cb/LEL meter prior to

16

and during entry of the structure. No readings other than safe levels were detected. The use of a FED/FED and Drager tubes was also discussed. After discussing other potential contributors to the odors detected in the building (i.e., other industries), the PADEP representatives left the site at 11:30 AM.

After the building was allowed to ventilate, Weavertown, WESA and ACHD entered the building. Edwin Watkins collected a water sample from the sewer in the subbasement of the lift station. Sample containers were identical to those employed for the initial sample from the landfill. Edwin Watkins indicated that the sample would be analyzed for VOCs and SVOCs. The water sample was slightly cloudy.

Weavertown staff noticed that the lowermost subbasement cleared of the strong odor first and rapidly, while the odor lingered in the overlying subbasement and ground floor as the air was gradually displaced. 6th Street Manholes

The two manholes were opened and inspected. One manhole was dry, without a discernible odor. The second manhole exhibited a minor odor that Weavertown and WESA identified as being similar to the odor detected at the pumping station, and not the landfill. Clear water was observed in the manhole. 1037 6th Street

WESA, ACHD and Weavertown inspected the vent and cleanout for the building sewer adjacent to the driveway. Weavertown opened the vent, and observed that the underlying trap was filled with water. In addition to the house sewer line, a second, much shallower line entered the riser for the P-trap vent. This line may be attached to the residence storm drains and/or floor drain located in front of the garage door. Summary and Conclusions

• The PADEP requested that available analytical data be submitted for the discharge from the oil/water separator. If approved by Hercules, analytical data in the Weavertown project file for the landfill (if any) could be submitted on Hercules' behalf.

• The Allegheny County Health Department collected water samples from the weir

structure at the landfill and from the 4th Street Pumping Station. Although uncertain, Edwin Watkins indicated that the samples would likely be analyzed for volatile and semivolatile organic compounds.

• Odors corresponding to the oil/water separator discharge were detected at low levels in

the weir structure and downgradient manhole on Stilley Street. • Strong chemical odors not associated with the landfill were encountered in the

pumping station. Slight odors of the same type were detected in the manhole on the corner of 6th Street and Burnette Avenue.

17

• All participants agreed that the strong odors in the pumping station were different and not associated with the landfill.

• The P-trap and vent at 1037 6th Street (the source of the complaints) appeared to be

intact and functioning properly. The P-trap was filled with water at the time of inspection.

• Brian Secrest indicated that the recent complaints apparently occurred immediately

after the blower in the pumping station was turned on. WESA staff now open the windows of the building when the blower is in operation.

• Due to the strong odors in the pumping station, a new blower was installed, which

forces air into the subbasements as well as the first floor of the pumping station. Even with ventilation of the first floor, slight pressurization of the subbasement may still occur, resulting in a reversal of vapors into the sewer line.

Note: A P-trap was installed on the second sewer line identified at the 1037 6th Street property

on. Since installation of the second P-trap, Hercules is not aware of further odor complaints from the residence. 2. STREAM SEEPAGE

Seepage was identified in the stream beside the treatment compound. A WEG representative walked the stream from above the compound to below the identified seep location. The seep entered the stream from the opposite side about 20 feet above the compound. The seep was iron-stained. The stream below this seep had a slight off-white film on the rocks, with a slight amount of foam at riffles. Above the seep, the stream was unaffected by the film or foam. Behind the compound, the stream had no film on the bottom and appeared fine. To 24 feet below the compound, there was no film on the stream bottom, just some slight foam accumulation at a small falls. At 27 feet below the compound, the film recurved on the stream bottom, and foam was present at the base of riffles, where the water was disturbed. Approximately 30 feet below the compound, adjacent to well P-5, there was a white film on the stream bottom and foam at riffles.

Starting at 80 feet below the compound, two, small product accumulations (about one centimeter in diameter) were observed to about 90 feet below the compound. A sheen and hydrocarbon odor was also observed. The material appeared to originate from the road side of the streambank. A sorbent boom and pads were located 90 feet below the compound. The sheen and film decreases rapidly downstream of the boom.

It is believed that the cause of the seepage is residual and not a landfill or post-closure failure. VI. Five-Year Review Process Administrative Components

Hercules and WEG were notified of the initiation of the Five-Year Review in September 2004. The Five-Year Review team was led by the EPA Remedial Project Manager, Rashmi Mathur, and

18

PADEP Project Officer, Barbara Gunther. Mr. Joseph Keller, Hercules Incorporated, and WEG representatives (Mr. Timothy Rarvasky, Kelly Hamilton, and Craig Wyda) assisted in the review. The review consisted of the following review components:

• Community Involvement • Documentation Review • Data Review • Site Inspection • Local Interviews

Community Involvement

Notice of the Five-Year Review and solicitation of comments was published in The Pittsburgh Post Gazette, local newspapers on April 11, 2005. The results of the review and the report will be made available to the public at the Jefferson Borough Building. The EPA and PADEP conducted community interviews in the immediate vicinity of the Site with residents having no issues with the Resin Disposal Site. Document Review

The Five-Year Review included the review of the following documents. The administrative documents were reviewed to provide historical Site conditions and risks, the design documentation and plans were reviewed to evaluate the system design, and the biannual reports were reviewed to evaluate current operating and analytical data trends.

• June 28, 1991 ROD for OU-1 • December 1992 Final RD Work Plan for OU-1 • February 1992 Consent Decree issued by EPA for Remedial Design and Remedial

Action (RD/RA) for OU-1 • December 1994 Final Oil/Water Separator Design for OU-1 • September 29, 1995 No Further Action ROD for OU-2 including long-term monitoring

of the groundwater was issued and Final Design for landfill cap and fence was approved by EPA

• September 1996 Administrative Order by Consent (AOC) for OU-2 between Hercules Incorporated and EPA

• September 19, 2000 First Type 1 Five-Year Review completed by EPA • Bi-Annual Progress Reports: No. 6 October 2000-May 2002, No. 7 June 2002-

December 2002, No. 8 January 2003-June 2003, No. 9 July 2003-December 2003, No. 10 January 2004-June 2004, No. 11 July 2004-December 2004

Data Review Groundwater Monitoring Operable Unit 1

WEG measures free product thickness and groundwater levels on a quarterly basis in on-site

19

wells PH-1, PH-2, PH-10, PH-11, TW-2, TW-7, TW-13, TW-14, TW-21, TW-22 and TW-24. Recoverable quantities of free product have been historically bailed from recovery wells PH-10, TW-2 and TW-14, and discharged into the Site oil/water separator. Since July of 1999, virtually no recoverable free product has been measured in Site recovery wells (Tables 2). Free product recovery was reduced from a monthly to the current quarterly frequency during 1999, due to the minimal thickness of free product measured in Site wells.

Quarterly groundwater sampling and laboratory analyses performed for OU-1 initially included on-site monitoring wells TW-7, TW-13, TW-14, TW-21, TW-22 and TW-23. Site-related indicator compounds included in the monitoring program include benzene, toluene, ethylbenzene, xylenes and naphthalene. Since the first quarter of 1998 through 1999, Site-related constituents were reported at detection levels or as non-detects in wells TW-7, TW-21, TW-22 and TW-24 (Table 3). Consequently, these wells were removed from the on-site groundwater monitoring program.

Groundwater samples have been collected from well TW-13 on a quarterly basis during the second 5-year report period. Analytical results for TW-13 are summarized in Table 3 and shown on Figure 3. Low to nondetectable concentrations of naphthalene, benzene, toluene, ethylbenzene and xylenes have been reported in the groundwater samples collected from TW-13 (Table 3). Groundwater samples have not been collected from TW-14, due to a measurable but unrecoverable thickness of free product on groundwater, and because there is insufficient water to collect a groundwater sample (Table 1). Operable Unit 2

Monitoring initially required under OU-2 included the quarterly sampling of off-site monitoring wells TW-17, TW-18, TW-19, TW-20, and TW-24, the quarterly sampling of three seeps (designated Seep 3, Seep 4, and Seep 5), and the sampling of residential wells during 1999. No Site-related constituents were detected in samples collected from the seeps or the residential wells during the first 5-year review period (Table 3). Consequently, the seeps and residential wells were removed from the OU-2 groundwater monitoring program during the second 5-year review period. Between the fourth quarter of 1998 through the fourth quarter of 1999, concentrations of Site-related constituents were reported at or below analytical detection levels in the off-site monitoring wells. The sampling of off-site monitoring wells was discontinued during the second 5-year review period. However, groundwater levels are measured in off-site monitoring wells on a quarterly basis, during the sampling of on-site monitoring well TW-13. Free product has not been observed in any of the off-site monitoring wells. Site Inspection

Inspection of the Site was conducted on June 22, 2005 by the EPA RPM, PADEP Project Officer, the Responsible Party and the Responsible Party's Consultant. The purpose of the inspection was to evaluate the protectiveness of the remedy, including the presence of the security fence around the landfill to restrict access, and the integrity of the monitoring wells. Institutional controls alerting buyers of the presence of the hazardous substances on Site to prohibit future development were put into place in 2002. No significant issues at the inspection were identified at any time regarding the cap, drainage features, fence or monitoring wells, thus there is no interference with the implemented remedy.

20

Interviews

The EPA and PADEP conducted community interviews in the immediate vicinity of the Site with residents having no issues with the Resin Disposal Site. A P-trap was installed on the second sewer line identified at the 1037 6th Street property. EPA and PADEP visited with the resident on 1037 6th Street property to get feedback from that resident regarding the installed trap with the trap installed. Since installation of the second P-trap, the resident was pleased with the trap and had no odor issues. VII. Technical Assessment Question A: Is the remedy functioning as intended by the decision documents?

Yes, the review of documents, ARARS, risk assumptions, groundwater data and the results of the Site inspection indicates that the remedy is functioning as intended by the ROD. The installation of an upgraded multi-layered cap for the contaminated soils and collection of leachate with an oil/water separator downslope of the leachate treatment system in which wastewater is separated from the oil with the oil being disposed off-site and wastewater going to a public waterworks prevents the migration of contaminants to groundwater and surface water to prevent direct contact with or ingestion of contaminants.

There is an opportunity to optimize the groundwater monitoring network. No Site contaminants have been observed in the following monitoring wells for two consecutive years: TW-7, TW-17, TW-18, TW-19, TW-20, TW-21, TW-23, and TW-24. The monitoring wells TW-7, TW-17, TW-18, TW-20, TW-22 and TW-23 should be sampled for one more year and then the EPA and PADEP will review the results to decide if the monitoring wells should remain in the groundwater monitoring program or be abandoned. Monitoring wells TW-19, TW-21, and TW-24 should not be abandoned, but be periodically sampled before each five-year review.

The institutional controls in place include access restrictions which shall help reduce potential exposure to contaminated groundwater until cleanup levels are achieved and prevent the disturbance of the cap. The restrictions employed consist of notices of restrictions on potential future land use. The restrictions cover any development, excavation or drilling on-site that could disturb covered or reconstructed areas and an existing security system including the construction of a fence around the perimeter of the Site containing a locked gate system. Access controls (fencing) are in place and successfully prevent exposure. These institutional controls were executed and recorded in August 2002.

Operation and maintenance of the cap, drainage structures, oil/water separator and monitoring wells has been effective as a whole. Hercules has contracted WEG to manage the Site and perform all O&M activities as previously described at a cost of approximately $12,000.00 per year, sampling and reporting at a cost of approximately $10,000.00 per year, and transportation and disposal at a cost of approximately $20,000.00 per year. Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAQs used at the time of the remedy still valid?

21

Yes, the physical conditions at the Site have not changed in a manner that would affect the protectiveness of the remedy. The applicable or relevant and appropriate requirements (ARARs) included in the ROD, such as the Safe Water Drinking Act (40 C.F.R. Part 141) from which many of the MCLs were derived, PA Safe Drinking Water Act (35 PS 722.1-721.17 and 25 PA Code Chapter 109), RCRA - Toxicity Characteristic Rule (40 CFR 261.3 (A) (2)), and PA Solid Waste Management Act (25 PA Code Chapter 7.261) continue to be met through the remedial action. In addition, there have been no changes in exposure pathways, toxicity, or other contaminant characteristics since the completion of the RD/RA in 1992. The remediation work conducted on the landfill has successfully reduced the risk to nearby residences and environment. Changes in Exposure Pathways, Toxicity and other Contaminant Characteristics

The exposure assumptions used to develop the Human Health Risk Assessment included both current exposures (offsite resident of all age groups, a trespasser who is a child and adult) and potential future exposures (young child, older child and adult aged onsite resident). There have been no changes in the toxicity factors for the contaminants of concern that were used in the baseline risk assessment. These assumptions are considered to be conservative and reasonable in evaluating risk and developing risk-based cleanup levels. No changes to these assumptions, or the cleanup levels developed from them, are warranted. There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy. Additionally, the groundwater contaminants levels have dropped so that there is no vapor intrusion issue in the resident's homes. The remedy is progressing as expected. Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No other information has come to light that calls into question the protectiveness of the remedy. Technical Assessment Summary

During the Five-Year Review, no issues were identified that currently prevent the remedial action from being protective. The systems operations/O&M appear have been optimized and are summarized in the Operation and Maintenance Section. The remedies and the physical conditions at the Site have not changed in a manner that would affect the protectiveness of the remedy. There is no other information that calls into question the protectiveness of the remedy. VIII. Issues

No Issues. IX. Recommendations and Follow-Up Actions

No Issues or Recommendations.

22

X. Protectiveness Statement

The remedy is protective of human health and the environment. All threats at the Site have been addressed through upgrading the multilayer cap of the contaminated soils and through the oil/water separator, collecting and separating wastewater and oil from the leachate collection system. (The wastewater is sent to the wastewater treatment facility and oil is collected and disposed off-site, thus preventing exposure to or ingestion of contaminated groundwater.) The fence around the landfill restricts access. The implementation of institutional controls, which alert prospective buyers of contaminants on-site and place prohibitions on future development, addresses future threat. XI. Next Review

The next Five-Year Review will be completed no later than five years from the signature date of this five-year review.

23

TABLES

TABLE 1: PRODUCT RECOVERY ACTIVITIESJANUARY 1996 THROUGH OCTOBER 2004

SECOND FIVE-YEAR REVIEW REPORTPICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH, PENNSYLVANIA

Well Jan-M

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22RecoveredCum. Total{gallons)

np

dry

005

np

np

np

0.01

np

np

Well Jan-97

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Total(gallons)

np

dry

0.05

np

np

np

globules

np

np

7.007.00

Well Jan-9S

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Total(gallons)

np

dry

0.02

np

0.01

np

0.01 5

np

np

0.500.50

Feb-M

np

dry

0.01

np

np

np

globules

np

np

Feb-97

np

dry

0.05

np

np

np

0.01

np

np

8.5013.50

Feb-98

np

dry

0.02

np

sheen

np

0.01

np

np

0.050.55

Mar-96

np

dry

0.2

np

np

np

globules

np

np

Mar-97

np

dry

0.04

np

np

np

<0.1

np

np

5.5019.00

Mar-88

np

dry

0.03

np

np

np

0.01

np

np

O.OS

0.63

Apr-96

np

dry

0.04

np

np

np

globules

np

np

Apr-97

np

dry

008

np

np

np

<0.1

np

np

7.00

26.00

Apr-96

np

dry

0.01

np

0.01

np

0.01

np

np

0.00

0.63

PRODUCT THICKNESS- FEETMay-96 Jun-96 Jul-9« Aug-9«

np

dry

006

np

np

np

globules

np

np

May-97

np

dry

0 13

np

np

np

<0 1

np

np

10.5036.50

May-98

np

dry

0.01

np

0.01

np

np

np

np

0.00

0.63

"P

dry

0.02

np

np

np

globules

np

np

Jun-97

np

dry

0 167

np

np

np

<0.1

np

np

10.0049.50

Jun-98

np

dry

0.01

np

0.01

np

0.01

np

np

0.000.63

np

dry

0.03

np

np

np

globules

np

np

Jul-97

np

dry

0 17

np

np

np

<0.0052

np

np

11.0067.60

Jul-98

np

dry

0.01

np

0.01

np

film

np

np

0.000.63

np

dry

0.05

np

np

np

globules

np

np

Aug-97

np

dry

008

np

np

np

<0.1

np

np

9.25M.75

Aug-98

np

dry

0.015

np

0.01

np

np

np

np

0.000.63

Sep-96

np

dry

004

np

np

np

globules

np

np

Sep-97

np

dry

02

np

np

np

<0.1

np

np

7.2574.00

Sep-96

np

dry

0.01

np

0.01

np

np

np

np

0.000.63

Oct-96

np

dry

0.04

np

np

np

globules

np

np

Oct-97

np

dry

0.1

np

np

np

<0.1

np

np

5.7579.76

Oct-96

dry

dry

0.016

np

0.005

np

0.01

np

np

0.000.63

Nov-SC

np

dry

002

np

np

np

globules

np

np

Nov-97

np

dry

008

np

np

np

<0.1

np

np

4-2564.00

Nov-98

dry

dry

0.03

np

0.01

np

0.01

np

np

<0.10.73

Dec-96

"P

dry

0.05

np

np

np

globules

np

np

63.00

Dec -97

np

dry

<0 1

np

np

np

<0 1

np

np

2.0086.00

Dec -98

np

dry

0.01

np

globules

np

globules

np

np

0.000.73

File E(»018\BAR10\Tabte1 Page 1 of 3 0*19/2005

TABLE 1: PRODUCT RECOVERY ACTIVITIESJANUARY 1996 THROUGH OCTOBER 2004

SECOND FIVE-YEAR REVIEW REPORTPICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH. PENNSYLVANIA

Well Jan-99

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Tola!(gallons)

np

np

0.01

np

001

np

001

np

np

0.000.00

Well Jan-00

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Tot»l(galloni)

--

--

---

0.000.00

Well Jan-01

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Total(galloni)

-

-----

0.000.00

Feb-9«

np

dry

001

np

0.01

np

0.01

np

np

0.000.00

Feb-00

-

-

-

-

-

-

-

-

-

0.000.00

Feb-01

np

np

001

np

0.01

np

globules

np

np

0.000.00

Mar-99

np

dry

0.01

np

0.01

np

0.01

np

np

0.000.00

Mar-00

np

dry

0.016

np

0.01

np

np

np

np

0.000.00

Mar-01

-

-

-

-

-

-

-

-

-

0.000.00

Apr-M

np

dry

0.01

np

0.01

np

0.01

np

np

0.000.00

Apr-00

np

dry

001

np

sheen

np

np

np

np

0.000.00

Apr-01

np

np

0.01

np

globules

np

globules

np

np

0.000.00

PRODUCT THICKNESS- FEETMay-99 Jun-99 Jul-99 Aug-99

np

dry

0.01

np

0.01

np

globules

np

np

0.000.00

May40

-

-

-

-

-

-

-

-

-

0.000.00

May-01

-

-

-

-

-

-

-

-

-

0.000.00

np

dry

0.03

np

0.04

np

003

np

np

0.240.24

Jun-00

-

-

-

-

-

-

-

-

-

0.000.00

Jun-01

-

-

-

-

-

-

-

-

-

0.000.00

np

dry

0.01

np

0.01

np

001

np

np

0.00 0.000.24 0.24

Jul-00 Aug-00

np

dry

0.01

np

sheen

np

0.01

np

np

0.00 0.000.00 0.00

Jul-01 Aug-01

np

np

0.01

np

001

np

globules

np

np

0.00 0.000.00 0.00

Sep-99 Oct-M Nov-M

np

dry

0.01

np

001

np

0.01

np

np

0.00 0.00 0.000.24 0.24 0.24

Sep-00 Oct-00 Nov-00

np

dry

0.005

np

np

np

np

np

np

0.00 0.00 0.000.00 0.00 0.00

Sep-01 Oct-01 Nov-01

np

np

0.02

np

globules

np

globules

np

np

0.00 0.00 0.000.00 0.00 0.00

Dec-M

-

-

-

-

-

-

-

-

0.000.24

Doc -00

-

-

-

-

-

-

-

-

-

0.000.00

Dec -01

-

-

-

-

-

-

-

0.000.00

File: E0018\BAR10\Table1 Page 2 of 3

TABLE 1: PRODUCT RECOVERY ACTIVITIESJANUARY 1996 THROUGH OCTOBER 2004

SECOND FIVE-YEAR REVIEW REPORTPICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH, PENNSYLVANIA

Well Jan-02 Feb-02

PH-1 np

PH-:_> dry

PH-10 001

PH-11 np

TW-2 globules

TW-13 np

TW-14 globules

TW-::1 np

TW-i!2 np

RKOVHTKJ 0.00 0.00Cum. Tobl 0.00 0.00(gallon*)

Well Jan-03 Feb-03

PH-1

PH-2

PH-10

PH-11

TW-2

TW-13

TW-14

TW-:>1

TW-22

R*covnr*dCum. Total(gallons)

np

dry

001

np

globules

np

globules

np

np

0.00 0.00

0.00 0.00

PRODUCT THICKNESS- FEET

Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02

np

dry

001

np

globules

np

globules

np

np

0.00 0.00 0.00

0.00 0.00 0.00

Mar-03 Apr-03 May-O3

np

dry

0.01

np

0.01

np

0.01

np

np

0.00 0.00 0.00

0.00 0.00 0.00

--

001

-globules

-

globules

-

-

0.00 0.00 0.00

0.00 0.00 0.00

Jun-03 Jul-03 Aug-03

np

dry

0.01

np

globules

np

globules

np

np

0.00 0.00 0.00

0.00 0.00 0.00

Sep-02 Oct-02 Nov-02

-

-

0.02

-

globules

-

globules

-

-

0.00 0.00 0.00

0.00 0.00 0.00

Sep-03 Oct-03 Nov-03

np

dry

002

np

globules

np

globules

np

np

0.00 0.00 0.00

0.00 0.00 0.00

Dec -02

-

-

-

-

-

-

-

-

0.00

0.00

Dec -03

-

-

-

-

-

-

-

0.00

0.00

Well Jan-04 Feb-04 Mar-04

PH-1

PH-2

PH-10

PH-1 1

TW-2

TW-13

TW-14

TW-21

TW-22

RecoveredCum. Total(gallons)

np

dry

0.01

np

globules

np

globules

np

np

0.00 0.00 0.00

0.00 0.00 0.00

Apr-04 May-04 Jun-04 Jul-04

np

dry

0.01

np

globules

np

globules

np

np

0.00 0.00 0.00 0.00

0.00 0.00 0.00 0.00

Aug-04

np

dry

001

np

globules

np

globules

np

np

0.00

0.00

Sep-04 Oct-04 Nov-04

np

np

globules

np

globules

np

globules

np

np

0.00 0.00 0.00

0.00 0.00 0.00

Dec -04

-

-

-

-

-

0.00

0.00

Fto E«i18\BAR10\Tabte1 Page 3 of 3 Oa/19f2005

DATA SUMMARY TABLE

QUARTERLY GROUNDWATER AND SEEP MONITORINGPtCCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH. PENNSYLVANIA

Lootlon

On-«a«MWl

TW-14

TW-21

TVV-22

Qfl-SlttUrd

TW-24

PtWM I Rl Semolina MHOtB T E X N

110J 740 4400 3000 110.000

n*> M rw nt> rw

ftt rw M (W M

rw IM rw iw rw

nd nd nd

FociMMl Rl Ivnnllna MttSlB T E X N

<230 MJ 140J 4400 MOO

4J TJ «J 230J MO

U U <10 U 7J

<10 <10 <10 <10 <11

U 1J <10 <10 1U

FlntaiwrtvllH

B T E mp-X 0-X N

« <9 <9 <3 4 <9

rw rw rw rw rw rw

<9 eg o <S o <3

O <9 <3 O O 0

<* «S <3 <9 ^ <S

OULOULOUL<flUL<5UL<9UL

hcomlQuvfeMHI

B T E mp-X o-X N

nm IM rw iw rw M

<5 UL <5 UL <5 OL <S UL <8 UL IL

<9 <5 <3 <5 <9 <9

"*

<0 <3 <9 «3 «3 <B

iaiLS

<J <3 <3 <j <3

Third Quoito 1|ff

B T E mp-X o-X N

rw rM IM rw rw rw

<3 <J <J <J <s I

O <3 <3 <S <3 <S

<8UL<AU1-<9UL'C9UL<3UL <flUL

Fourth Ouvtor 1Ht

B T E mp-X e-X N

rw rw rw rw rw rw

<a <s «s «a <s <t<S <3 <3 <3 <3 <S

<9 <3 <S <i <»

<S <J <3 <3 <3 <3

<3 « 4 <S <S

LociOon

On-«IM y W.

TW-7

TY»-21

1W-22

TW-23

OH-MHIIW.

TVV-17

TW-11

TW-20

TW-M

«MP>

«W>4

SM»9

Flret Qyintr lift

B T E mp.X O-X N

<3 <fl O <3 <3 <3

<3 <9 <J <3 <5 «

<S <S <S <S <3 <S

O <3 <9 <S O <3

«« <3 O <3 <3 *3

<a <3 <s <a <9 4

<s <s <a <s <3 o

<a <s <a <s <s o

<g <5 <J <5 <3 <J

<3 <5 <3 <5 <3 <S

<3 <3 <3 <3 <5 <9

Mcqrm Qiwiur im

B T E mp-X O-X N

<9 <S <9 <9 <3 <3

<3 <3 <3 <S <3 <9

<3 <J <3 <3 <3 <«

<5 <3 <5 <S O «9

<9 O <9 <9 <3 <5

<S <3 <5 <5 <5 <S

<9 <9 0 <3 <S <S

4 <S <3 <3 <3 <3

<S <S <S <S <3 <5

<3 <3 <J <3 <3 <3

<3 0 <3 <3 <J <J

TUrt QwVwT1>n

B T E mp-X o-x N

<3 <3 <S <9 <3 <3

O <3 <3 <3 <5 O

<S O <9 <9 <5 0

<S <S <S <S <S <S

<S <S <9 <0 <9 <9

<3 <3 O <3 <3 <3

<J <5 <3 <J <3 <3

<a <a «» <s «a <»

<J <S <3 <3 <3 <5

<3 <S <S <S <9 <5

<5 <5 O <3 <5 <5

Fnrth Qutrtv t*1f

B T E mp-X o-X N

o <a <a <s <s <s

<S <S »S <S <3 «3

<3 <S <S « <J <S

«9 <9 <9 <9 <3 <5

<3 <3 <5 <5 O <9

<9 O <9 <9 <9 <9

<S <3 <8 <8 <» -3

< <9 <S <5 4 <9

<8 <3 <8 <3 <9 <3

<9 <3 <9 <9 <9 <9

<S <5 <S <3 <S <3

Kr*.B- b*nz*n* o-X •T • toJuof.1 N - rukpMrutcn*E - rthvttMnam nd - not d*t«ct*tlmp-X - m and p x\ • -not ump»»d

J • QtMntUvltofi « ippnuam..* du* to ltfrrtOmA dirtig ttw QA. rtv-w.

L - Thto axnptound fcs |ii-»i< in (habut (ha raponnH rMulls may b* h4»id low Alo vi taut* kl.rtA»d dtrtng lh« QA rwkiw

UL - Thta compopund WM not iMtdiKl, but thequ.v.HMton Umlt to protwWy htohtf dw lo • kMM U*ntlnM dunng U» QA nwkM

ttom1 Ml ***** r««Jw rooortod I

dtflng tht ouvltvtv rrantarina VMnlJdu» to u» PTJ.MIH of product m th» MM.TW-14 to p*t of th» product rwovwv **<

3 TW-ifl can not bt> Mmptod du* to motMtrucUon tn the wM

Soap tocatnn ktartrfcaOon and Pdid not comm«nc« unll In* Mcond quarli.lvrrtonrtonna *v*nt ol 1 000

E001«\8AR11W3WF Pag* 1 of 4

TABLE i: DATA SUMMARY TABLE

QUARTERLY GROUNDWATER AND SEEP MONITORINGPICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH, PENNSYLVANIA

Location

On-flttMWJ

TW-13

Qff-Slta MWi

tMOt

Flnl Qmrttr 2WG

23 12 47 12 110 MO

ftcond Qpaftar 2000

B T E X X N

12 <5 21 42 31 210

Thlrt Qiajfttf 2m

<3 0 30 29 42 210

Fourth Quarter 2000

B T E X X N

0 0 11 1 11 M

K*Y.B - banzana

E • athvltwuana nd - no) datactadmp-X - m and p r, - no( tamplad

J • QuartrtMlon * approwmaia dua toriartrfwd (fcxtno Ina QA ravww

L • Thiit>ul Iharaportradloan

f m«v b* kimt* kw AJhna tt» QA r*vww

L • Th« compopurtf WM not (M«cUd. twt If*quwiliLiLton l«nd « grabaUv NaUr du* to • kmDIM KtenhfiM OLTWX) If* OA iwww

U nportvJ in uoA (ppo)1 AH Brutvl

2 TVM4 W**wg th» quvlvtv monrionng wvrtsdu* lo in* pfM^ca of produd m lha w«l

3 TW-18 can not EM MmpM du* to «nn In lh* w^t.

SMP location vtantfetflon and •ubawmanldid not commanca jnU tha aacond guartarly

o avani of 1 0OB

Location

QltSttcMWl

TW-13

TW-22

Off-Slta UW.

9««ff

Pint Qwftf 2m

B T E mp-X o-X N

• <S 24 21 M 100

facond QiMrtar 2001

B T E mp-X o-X N

• <S 1 t 14 U

TWrt Quuttr XM1

B T E mp-X o-X N

<5 <5 <S <s <5 <&

fourth Quarter 2001

B T E mp-X o-X N

<5 <i <5 <3 <3 ^5

TABLE 1: DATA SUMMARY TABLEQUARTERLY GROUNDWATER AND SEEP MONITORING

PICCO RESIN DISPOSAL SITEJEFFERSON BOROUGH, PENNSYLVANIA

Location

Qn-iBfMWJ

TW-13

TW-14

Qfl-SHa MWl

torn

f iraf pugfitr 2W2

a T E mp-X o-X N

<5 <3 <S <3 <3 <8

rw na rw na rw rw

Second Quarter 2002

B T E X X N

<5 <0 <0 «3 0 12

rw rw rw rw na rw

Third Quarter 2002

<3 <3 <5 0 <3 20

rw rw ru rw ru rw

Foiirffi Quartar 2<htt

B T E X X N

<3 <5 7 • T 40

rw rw rw rw rw rw

TABLE 3: DATA SUMMARY TABLEQUARTERLY OROUNDWATER AND SEEP MONITORING

B - baruvw o-X • o-xywnaT - toiuana N • rwphthaJanaE • •ihvftwnnrw nd • not dalacladmp-X - m and p K> • -no* tampladn> • rut Mm0«j dua to product

J - Quartriahon • approaimaia dua lo lKtantlTwd during lha QA ravww

L • Thu compound v umi< In th* Mmpli.bul Iha raportrad rMultt may ba txaMd tow duato an «aua KMrtifwd during lha QA ravww

UL • Thu compopund waa nrt dalactad. bul (haquanlitalion IkmH x protoaWv hlohar Out lo a lowbtac idanttfia* duhru trw QA ravww

1 Ajl analylcri rwulU rvportad in UQ/L (pptol

2 TW-14 WM rw4 umpwd (or groundwalar arwlvM*dunng tha quartartv rrartlortng avartidua to the praaanca of produa in tha wallTW-14 w part of (ha product racovarv w

3 TW-18 can not ba wmpiad doa to anobalruclton In lha wail

4 Saap tocMkxi tdantNlulon and •utWMuant aampltnadhj not comrrwnc* untl (ha noond quarwrtymonrlonng avarri of 1980

PICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH. PENNSYLVANIA

Location

Qn-8IU MWa

TW-13

TW-14

Off-Site MWl

s»«

Flrmt Quarter 20tU

B T E mp-X o-X N

0 O <S <9 <S <S

rw na rw na na rw

Sacond Quartaf 2003

B T E mp-X o-X N

O <s <0 <9 <9 <3

na rw na na rw rw

Thirt Ouartar 2O03

B T E mp-X o-X N

0 <9 <9 <3 <5 15

Fwrtfi Qutftfr ?W3B T E mp-X o-X N

<9 <9 <3 0 <3 31

fw rw rw na na rw

o-X-o-xv4anaT • loiuana N - rwpNrwMfWE • aihylbanzana nd - not cMadadmp-X - m and p x> - - not aampwdna-not kamplad dua lo product

J - QuanUalion ta appmnmala dua to ttmnaUonad dunng lr» QA ravww.

L - Th« comptaurd w praaanl mlhaaampl*.but tha raportrad raaulls may ba biaaid kow dualo an Maua tdantHwd dunng (ha QA nwww

UL • Thia convopund MB not daladad. but lhaqwHMMionlimil M probably Nghar dut to • towMM idantflai during lha QA raviaw

1. AlarwIvtlcdraaultaraportadinuoAfppt}

2 TW-14 WM not wmpiad for groundwitw arufvaa*Ouring thi quartartv momlonna avantidua to iht praaanca of produd m tha trcllTW-14 a owl of (ha product racovarywdl natwork

3 TW-10 can not ba lamplad dua lo an

did not cammanca untl trw aaoond guvlartyfl av*K of 1900

E001B\BAR11\OW Raaulli Paga3of4

TABLE 1: DATA SUMMARY TABLE

QUARTERLY GROUNDWATER AND SEEP MONITORING

PICCO RESIN DISPOSAL SITE

JEFFERSON BOROUGH, PENNSYLVANIA

Location

QrvlJtoMWt

TW-14

9ff-aU*MWff

•MM

B T E mp-X o-X N

ru ru nt nt ru ru

B T E mp-X o-X N

ru n* n* ru ru ru

B T E mp-X o-X N

ru ru ru ru ru ru

B T E mp-X o-X N

ru ru ru ru ru iu

T - lotuwu€ - «hvlb«nwwmp-X - m ml p nn« • not iwnptad dua Us product

nd • not

J • Qu*ntn««n )• Mwroximat* du* to llmdidon*•J iJrfwd duvxj lh» OA. nvuw

L • Thi complound w piMani m (ru ««np(«,but in* rvportrwl rwulti m*v tu bia*«d low <K*

to w IMIM KMrtrfwd dunng th* QA r«vWw

UL • Ttva cofnpopund MM not ttowcwd. but iru4u*ntil«twn limit w probaUy Ngrui du« lo • lubiu Ktenlrfw* dunno tru QA WMW

1 AH irufvticd r»*JH r«cxx1*d In utf. (Dot))

2 TW-14 MM nM umpM lor graurehntar WU!VM«durmg IT* quarwrtv morttortng «v«n(idu» lo tht prujrci of product In Iru w«iTW-14 wpviollru product r*covOT ««l r

obstruction in trw w«N

4 SMO toc«lKXi KtontirtcMton and tubnqMnldid not cofnrr>*nc* unll lh« Mcond gujfltriymonlonng «vvri of 1 0OB

EOOIff^AR! VOW Rnutti

ATTACHMENTS

Figure 3Response Actions Plan Sampling Locations

ppronmott Locancv

PlCCO'.Rnn Lwtfill

ApproxitnfttSite PrcpmyBoundary

Lodfrs Run Cemetery

Number* B**ed onOnrrvil Rl (Wwton. !»'• U!

Resin Disposal Five Year ReviewLandfill

Resin Disposal Five Year ReviewLandfill

Resin Disposal Five Year ReviewOil Water Separator